Medicare Compliance & Reimbursement

Hint: Just because something is proposed, doesn’t mean CMS follows through on it.

There were a couple of Quality Payment Program (QPP) proposals that Medicare decided not to go through with in the (CY) 2024 Medicare Physician Fee Schedule (MPFS) final rule. Both have to do with QPP threshold amounts, but they’re for different performance years.

First: The Centers for Medicare & Medicaid Services (CMS) didn’t use the data from the mean final score from the 2017 through 2019 performance periods to determine the performance threshold for 2024, as originally proposed last July.

“We are not finalizing our proposed policy to identify the ‘prior period’ by which we will establish the performance threshold as three performance periods, instead of a single prior performance period, beginning with the CY 2024 performance period/2026 MIPS payment year,” the final rule notes. Instead, CMS chose to use MIPS data exclusively from the 2017 performance period/2019 payment year to “determine the performance threshold for the CY 2024 performance period/2026 MIPS payment year,” the rule expounds.

Thus, the agency finalized the performance score for CY 2024 at 75 points basing the mean final score from that performance period/payment year under this methodology.

Second: Due to stakeholder concerns that there would be “unintended consequences of accelerating the data completeness thresholds too quickly” and possibly “jeopardiz[ing] MIPS eligible clinicians’ ability to participate and perform well under MIPS,” CMS backed away from its proposal to hike up the data completeness threshold sooner rather than later, the rule says.

As it stands, CMS will keep the MIPS data completeness threshold at 75 percent through the 2026 performance year. This would allow MIPS-eligible clinicians, groups, and APM entities to stabilize before a transition and better manage current data completeness threshold requirements. However, beginning with the 2027 performance period/2029 payment year, CMS aims to increase it to 80 percent.

Resources: Review current past and current performance year guidance at https://qpp.cms.gov/ and find the QPP 2024 final rule published in the Federal Register on Nov. 16 at www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other.